On June 8, 2023, Jay Nanavati moderates a panel titled “Puerto Rico’s Act 20/22 Tax Incentive Program: Residency And Sourcing Under The IRS’s Microscope” at the 2023 NYU Tax Controversy Forum.

Description:

Since their passage in 2012, Puerto Rico’s Acts 20 and 22, known together as Act 60 since 2019, have encouraged many individuals and businesses from the U.S. mainland to relocate to Puerto Rico. The tax benefits that Act 60 provides encourage taxpayers outside Puerto Rico to boost the Puerto Rican economy by investing, doing business, and residing in Puerto Rico. As with any tax benefit, though, Act 60 is vulnerable to abuse. This panel discusses the IRS and the DOJ’s scrutiny of taxpayers’ claims of bona fide residency and Puerto Rico-sourced income.

Moderator:

• Jay R. Nanavati, Esq., Partner, Kostelanetz, Washington, DC

Panelists:

• Timothy P. Noonan, Esq., Partner, Hodgson Russ, New York, NY
• Carlos F. Ortiz, Esq., Partner, Baker & Hostetler, New York, NY
• Victor Song, Chief Operating Officer, Integritas3, Seattle, WA

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